My family and I do not support Atlantic Gold's Beaver Dam Mine Project

Scott Beaver

Aspen, NS

B0H1E0

Beaver Dam Mine Project

Impact Assessment Agency of Canada

200-1801 Hollis Street

Halifax, Nova Scotia, B3J 3N4

Email: bdmine-minebd@iaac-aeic.gc.ca

My family and I do not support Atlantic Gold’s Beaver Dam Mine Project.  Allowing this project to proceed would be irresponsible at all levels of government.  Atlantic Gold has proven they are not trustworthy or capable, in terms of our environment, to safely construct and operate projects of this size, especially when piecemealed together as Touquoy, Beaver Dam, Fifteen-mile Stream and Cochrane Hill. 

I have personally witnessed an elderly man violently thrown out of a public community meeting by the RCMP on the command of Atlantic Gold company officials.  John Perkins, now 70 years old, filed a lawsuit against AG in 2019 because of what unfolded May 23^rd at the Sherbrooke Fire Hall.  There were many witnesses at the community meeting on that day, many of whom are ready and willing to testify when this shameful community event makes its way through the court system.  This man did nothing more than ask intelligent, pointed questions about the tailing’s impoundment planned for Cochrane Hill.  There certainly was no exchange remotely close to warrant actions taken that day by AG.  https://www.halifaxexaminer.ca/province-house/roughed-up-by-the-rcmp-john-perkins-sues-atlantic-gold-and-the-cops/

On February 14^th, 2019 President, COO, and Director of Atlantic Gold Maryse Belanger wrote a threatening letter to Nova Scotia Ministers.  This communication has left me shocked and disappointed.  I find it hard to believe that AG feels that strong-arming Nova Scotia communities would be a tactic that could work.  The letter is shameful, unprofessional, and yet another example of why this company can not be trusted to operate such an environmentally wasteful and risky operation. 

Copy of Maryse Belanger’s letter referenced above: 

Maryse Belanger
President, COO and Director
Atlantic Gold Corporation
 

Dear Minister Mombourquette, Minister Porter and Minister Hines,

We need your support. Future development and rural jobs are at risk. I am writing to you today to express disappointment and concern at the actions of the St. Mary’s Municipal Council and their approach to ‘consultation’ around the proposed Cochrane Hill Gold Mine Project. To begin and as you are probably both aware, Atlantic Gold is a highly reputable and progressive mining
company currently operating the successful Touquoy mine in Middle Musquodoboit, Nova Scotia. We currently employ over 280 full-time staff and 40-70 contractors at our site, over 95% of which are native Nova Scotians. Atlantic Gold’s successful operation at Touquoy meets or
exceeds every safety or environmental standard from the federal or provincial governments. We
are proud to have helped bring vibrancy back to a community in rural Nova Scotia and we are proposing to do that again with future mining sites at Beaver Dam, Fifteen Mile Stream and Cochrane Hill.

Specifically related to the Cochrane Hill Project, we have been working with the St. Mary’s Council to give them a greater understanding of our company, our practices and the
benefits that our proposed development at Cochrane Hill would bring to rural residents. It is
acknowledged by the Council itself that they have no regulatory authority over the project. However, our staff have presented on multiple occasions in Council Chambers, liaised with Councillors individually and hosted a tour of our Touquoy site for the Council and senior staff to better understand the mining process to alleviate their concerns and hopefully, the concerns of some of their constituents. A few weeks ago, St. Mary’s Council hosted consultation sessions for
residents living within five kilometres of the proposed site and specifically asked Atlantic Gold not to attend. We were not comfortable with this approach and made council aware of our concerns. As a show of respect to Council, we abided by this request as it was a closed session and any local opposition groups were being restricted access as well. However, this week (February 12 & 16), St. Mary’s Council has hosted what they are terming as ‘Public Meetings’ to discuss Atlantic Gold’s proposed mine at Cochrane Hill. With more than two weeks notice,
Atlantic Gold informed the Municipality’s Warden (Michael Mosher) and CAO (Marvin MacDonald) that two company representatives would attend both meetings but only to listen to the discussion with the goal of addressing any concerns in future communications. On the evening of February 11th, the St. Mary’s CAO informed Atlantic Gold that at the request of Council, we were being asked not to attend the ‘public meetings’. Atlantic Gold wrote and called the CAO on February 12th to ask them to reconsider this request and informed them that we are of the opinion that this action violated the Municipal Government Act. In response, we were again told that we would not be allowed to attend. For Atlantic Gold, this is a serious matter and while we converse with your offices, we are exploring legal remedies as well. Atlantic Gold believes and encourages healthy dialogue about our proposed project but having one-sided ‘consultation’ sessions to which we are being excluded does not follow due process, Intended for Public Use regulations and only moves to widen divides between residents rather than building consensus and understanding.

In closing, I am making two requests of the Nova Scotia Department of Municipal Affairs:
1. Atlantic Gold asks that an official communication be sent to the St. Mary’s Council and CAO to inform them that their consultation sessions of February 12 and 16 were in violation of the
Municipal Government Act.
2. Atlantic Gold also asks that the Province re-enforce to the St. Mary’s Council that they have no legal or legislative authority over this project and that, given their one-sided approach to public consultation, none of their actions or decisions will be recognized as part of the provincial
government’s decision-making process as it relates to the approval of the Cochrane Hill Gold
Mine. Although St. Mary’s Council does not have any legislative authority in the approval of this project, they do have a public forum to speak to residents. If one-sided, anti-development activist driven, efforts like this continue outside the rule of law, Atlantic Gold runs the risk of losing
any public support and potentially the end of the project itself. Aside from having very negative impacts on our company, the loss of potential jobs and revenue to rural Nova Scotia would have a ripple effect for further investment by other companies in this area of the province. We Sincerely hope that this is not how the provincial government would like the industry to evolve.
I look forward to your response on this matter at your earliest convenience.

Regards,
Maryse Belanger
Intended for Public Use

How can the public feel confidence in our government and the environmental process when, on one hand, our planet is facing unprecedented climate/wildlife crises and on the other we are allowing multinational industry full access to our most precious resources, taking advantage of antiquated mining legislation.  Why would we consider mining gold at all in our province?  Gold mining has some of the largest human and environmental impacts (https://www.google.com/url?q=https://miningwatch.ca/blog/2019/2/5/gold-facts.&sa=D&source=editors&ust=1639333284213000&usg=AOvVaw2AF9NKgLEZbGUMb9pjCx89) of all types of metal mining.  Gold has not been identified as a critical mineral in the Canadian Federal Critical Mineral list (https://www.nrcan.gc.ca/our-natural-resources/minerals-mining/critical-minerals/23414).  Two things we all can agree on for sure is that gold is not a critical mineral and, in fact, humans have already mined more than enough of it throughout the planet to meet our needs.  We have an environmental obligation to only mine what is necessary and to mine those minerals in areas that are not counter productive to years of Environmental work. 

Nova Scotia Salmon Association West River Project and fish habitat is a stone’s throw to the Beaver Dam proposed open pit gold mine and has been in operation for many years.  This mine threatens its very existence and because of this should not be allowed to proceed.

https://www.halifaxexaminer.ca/environment/we-cannot-imagine-two-locations-less-suited-for-extractive-projects-such-as-gold-mining/

Perhaps it would be helpful to only allow underground mining operations in NS considering the massive waste open pit mining produces as well as the environmental impacts these mines present.  

Table 3.2-1: Summary of Alternative Means of Undertaking the Project on page 47 of the EISS there is a reference to mine types.  Surface Mine vs Underground Mine.  Just because St. Barbara believes an underground mine is not economically feasible doesn’t mean it can’t be done and done in a more environmentally friendly manner.  Open pit mining’s very nature is much more destructive and produces much more waste product than underground mining.  Open pit mining is considered one of the planets most destructive industries. 

Mi’kmaq of Nova Scotia do not support this project.  It would be irresponsible to move forward with this project on that basis alone.  Let’s not head down an old path and repeat colonialist actions as we have done before.  Perhaps its time to look at mining reform in Nova Scotia and bring our antiquated legislation back into the 21-century aligning it with climate change, reconciliation, the wildlife crisis, and communities directly impacted.      

B.C. Fails to Meet Indigenous Consent Standard

https://mailchi.mp/miningwatch/bc-fails-to-meet-indigenous-consent-standard-new-report?e=864ecd0bd6

Mining reform in BC

https://reformbcmining.ca/news/2021/10/first-nations-legal-action-challenges-b-c-s-colonial-mining-law-groups-urge-reform/

After Atlantic Gold was sold to St. Barbara, its Extractive Sector Transparency Measures Act reports (https://www.nrcan.gc.ca/our-natural-resources/minerals-mining/extractive-sector-transparency-measures-act/links-estma-reports/18198) disappeared from the archives.  A fine example of a non transparent company intentionally hiding information.

This project will clearly cause deforestation and land degradation.  Moving ahead would be inconsistent with Canada's position and the federal government's endorsement of most recent commitments under the Glasgow Leaders Declaration on Forests and Land Use (https://ukcop26.org/glasgow-leaders-declaration-on-forests-and-land-use/) which we have seen negotiated on November 2^nd 2021.

The federal process must consider AG’s four proposed mines in Northeastern Nova Scotia and the cumulative effects they will have in the region.  There is no report on the cumulative effects of depositing multiple mine site tailings into the proposed spent pit at Touquoy.  I find this troubling in many ways and is another example of a piecemeal approach and disregard for environment. 

Considering the very close proximity of Touquoy, Beaver Dam, Fifteen Mile Stream and Cochrane Hill the proposed use of haul roads has environmental trouble written all over it.  The ore transportation between these four sites introduces a risk of contamination for waterways along the route and heavy metal dust pollution.  According to section 2.3.2 of the Beaver Dam Mine Project Environmental Impact Statement Summary (October 2021) This ~31km road will be used to haul ore between the two locations 190 times per day for 16 hours each day, 350 days a year, for 5 years.  One must consider that this area is one of the last wintering grounds used by endangered mainland moose.  NS has recently adopted a Mainland Moose recovery plan (https://www.cbc.ca/news/canada/nova-scotia/mainland-moose-recovery-plan-species-at-risk-1.6264061) and it doesn’t appear that this company has given any honest effort to understand moose and their very important and limited habitat.  My hope is that our government will give this issue much deserved attention.  Besides the transport route, important wetlands of significant concern will be destroyed and wetlands serve many important ecological functions for not only moose but a variety of wildlife. These four giant open pit mines will have an everlasting negative effect on moose territory in the region.

I want to see much more detail on how this giant open pit mine site will operate when we encounter severe weather events?  As we know these events are becoming more and more frequent.  North Carolina is one of many examples of recent weather that the Eastern Seaboard has come to expect.  Hurricane Florence dumped 25 inches of rain in four days in parts of Wayne County.  How will Atlantic Gold deal with rain events like this? 

Canada has a quarter of the world’s soil carbon (https://www.google.com/url?q=https://www.cbc.ca/news/science/wwf-carbon-ontario-peatland-ecosystems-1.6244304.&sa=D&source=editors&ust=1639333284217000&usg=AOvVaw0HUk83m4CETsriRWJEPq5G) and keeping it in the soil will avoid further global warming.  Again, we do not need more mined gold and gold has not been identified as a critical mineral in Canada or the US.  How can we allow such a project with a proven track record of environmental fault to proceed? 32 provincial environmental charges (https://www.spglobal.com/marketintelligence/en/news-insights/latest-news-headlines/st-barbara-unit-faces-32-charges-over-alleged-infractions-at-canadian-gold-mine-61888435) and 3 federal charges are very concerning and leaves me wondering how this company could manage these projects and our environment at the same time? 

Three charges laid by Environment Canada on March 21, 2021 under the federal Fisheries Act relate to sedimentation and fish habitat.  Court documents list these three charges: 

Fail to sample effluent for an acute lethality test from an unauthorized deposit of a deleterious substance, to wit: sediment bearing effluent, into water frequented by fish, to wit: an unnamed, fish bearing watercourse at the Touquoy mine site, in violation of s. 31.1(1) of the Metal and Diamond Mining Effluent Regulations and did thereby commit an offence contrary ta s. 78 of the Fisheries Act.

Fail to notify without delay of an unauthorized deposit of a deleterious substance, to wit: sediment bearing effluent, into water frequented by fish, to wit: an unnamed, fish bearing watercourse at the Touquoy mine site, in violation of s. 38(5) of the Fisheries Act, and did thereby commit an offence contrary to s. 78 of the Fisheries Act.

Fail to provide a written report of an unauthorized deposit of a deleterious substance, to wit: sediment bearing effluent into water frequented by fish, to wit: an unnamed, fish bearing watercourse at the Touquoy mine site, in violation of s. 38(7) of the Fisheries Act, and did thereby commit an offence contrary to s. 78 of the Fisheries Act.

Finally, provincial royalties are simply inequitable and leaves our municipalities with literally no royalties from these short-term grab and dash mines, yet municipalities bear every bit of environmental risk.  It’s concerning to me that this company can report that they are one of the world’s cheapest producers of gold on the planet.  In contrast Nova Scotians receive one of the worst royalty rates on the planet at only 1% of net while other jurisdictions are at 5-7% of gross.  

Thank you for the opportunity to respond.

Respectfully, Scott Beaver and family

Aspen NS